ABC Compliance Regime A Practical Perspective Gillian Swaby ABC - PowerPoint PPT Presentation

ABC Compliance Regime A Practical Perspective Gillian Swaby

ABC Compliance Regime A Practical Perspective The ABC compliance regime — What do you already you have? • Code of Business Conduct & Ethics. • Code of Conduct for Directors. • Whistleblower Policy. • Clausing in Contracts. — Then comes the ABC Compliance Guide…. • Be careful of total focus on “foreign bribery”. 1

ABC Compliance Regime A Practical Perspective ABC Compliance Guide 2

ABC Compliance Regime A Practical Perspective How to roll out: — 2 African minesites. — Country offices. — Exploration. — Head Office. Trickle down approach AND DON’T FORGET TO LOOK OUTSIDE THE FENCE 3

ABC Compliance Regime A Practical Perspective Many iterations of presentation and speaking notes: — Presentation to senior management group in Perth/senior visitors. — Video presentation to senior managers on sites. — Less complicated and less legalistic speaking notes/ powerpoint to sites. Appointed champion at each site to undertake training to supervisor level. Records – back to head office. Site based Anti-Fraud & Corruption Procedure initiated, mailed to everyone. 4

ABC Compliance Regime A Practical Perspective Workers’ levels: — Differences in sites. — Level of education/language. — Drama group. — Book. — Posters – cultural. 5

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ABC Compliance Regime A Practical Perspective In Summary: Be aware of your “audience”. Keep it simple without losing the message. Spread the responsibility for training. Keep it relevant and use all opportunities to get the message across. 11